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Internal Revenue Code (IRC) Estate Planning

DarrowEverett LLP

Business Succession Planning: Pros and Cons of Passing S Corp Shares in Trust

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Business succession planning and estate planning are often linked together, particularly in the case of closely held family businesses. In the case of a shareholder who wishes to pass along their shares of an S corporation as...more

Bilzin Sumberg

Do You Know Where Your Gift or Bequest Is Coming From? If Not, You May Be Subject to a Gift/Inheritance Tax and the Related New...

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Pursuant to Internal Revenue Code Section (“Code §”) 2801, if you are a “U.S. Beneficiary” - who is the recipient of a gift or bequest from, or a distribution from a trust established by, a former U.S. citizen or former Green...more

Hone Maxwell

When is a U.S. International Tax Attorney Needed?

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Individuals and businesses are frequently navigating transactions that span multiple countries. These transactions are often complex, as they navigate multiple jurisdictions’ unique — and often complicated — taxation systems....more

Proskauer Rose LLP

Wealth Management Update - June 2025

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The June 2025 Section 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and GRATs is 5.00%, which is the same as the April 2025 Section 7520 rate...more

Freeman Law

Residency for Federal Taxation

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Residence may seem to be a relatively simple thing to determine. It’s where you live, right? Well, leave it to the Internal Revenue Code to complicate this question. There are different tests for residency when it comes to...more

Proskauer Rose LLP

Wealth Management Update - May 2025

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The May 2025 Section 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and GRATs is 5.00%, which is the same as the April 2025 Section 7520 rate...more

Bressler, Amery & Ross, P.C.

How to Take Advantage of Changes in Interest Rates For Gift and Estate Tax Savings

A recent Tax Court order highlights the gift and estate planning opportunities afforded when a senior family member makes loans to other family members. In Galli v. Commissioner, Docket Nos. 7003-20 and 7005-20, the Court had...more

Proskauer Rose LLP

Wealth Management Update - April 2025

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The April 2025 Section 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and GRATs is 5.00%, which is 0.40% less than the March 2025 rate. The April applicable federal rate (“AFR”) for use with a...more

Allen Barron, Inc.

Create a New Trust or Update an Existing Estate Plan

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If you wish to create a new trust or update an existing estate plan, you will need skill and expertise across many disciplines: tax, estate planning, and legal services. Look for a service provider who can seamlessly...more

Gerald Nowotny - Law Office of Gerald R....

To Be or Not to Be Contemplating the Meaning of Life Through Private Placement Life Insurance

The focus of this article illustrates why private placement life insurance (“PPLI”) is the best asset to utilize in the “Buy, Borrow and Die” strategy for high net worth investors including billionaires. After this article,...more

Foley & Lardner LLP

Benefits Basics - When an Employee Dies: A Resource Guide for HR & Benefits Professionals

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As a member of your company’s human resources or employee benefits department, one of the most difficult calls you may receive is from a colleague or an employee’s family member notifying you of the death of an employee. This...more

Rivkin Radler LLP

Transferring the Family Business To A Private Foundation? Are You Sure About That?

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Charitable organizations are dependent, in no small part, upon the financial support of many successful business owners. The generosity of these individuals and their organizations may be a manifestation of several factors...more

Frost Brown Todd

Advanced Section 1202 (QSBS) Planning for S Corporations - UPDATED March 2025

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Section 1202 provides for a substantial exclusion of gain from federal income taxes when stockholders sell qualified small business stock (QSBS). But a number of requirements must be met before a stockholder is eligible to...more

Offit Kurman

Not Considering the Importance of Charitable Giving

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When a client’s family does not wish to inherit a collection or if its inclusion in the estate would create a significant tax burden, it is crucial to explore charitable giving options. Proper planning can help maximize the...more

Proskauer Rose LLP

Wealth Management Update - March 2025

Proskauer Rose LLP on

March 2025 AFRs and 7520 Rate - The March 2025 Section 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and GRATs is 5.40%, which was the same as the February 2025 rate...more

Gray Reed

Understanding IRS Private Letter Ruling 202504006: Crucial Takeaways for Tax Planning

Gray Reed on

The Internal Revenue Service (IRS) recently issued Private Letter Ruling (PLR) 202504006, addressing several important estate and gift tax questions related to the division of a marital trust and the subsequent disclaimer of...more

Kohrman Jackson & Krantz LLP

Act Now or Pay Later? Will Congress Extend the Higher Estate Tax Exemption Before 2026?

As we approach the end of the first quarter of 2025, estate planners and their clients are closely monitoring developments in Washington, D.C. The scheduled sunset of the increased estate and gift tax exemption is now less...more

Offit Kurman

Death Tax Repeal Act

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On February 13, 2025, Republican lawmakers in Congress introduced the Death Tax Repeal Act, which aims to permanently eliminate the federal estate tax. Since 2015, various legislative efforts to repeal the estate, gift, and...more

Davis Wright Tremaine LLP

Watch the Sunset: Federal Estate Exclusion Set To Shrink in 2026; New Changes on the Horizon

The 2017 Tax Cuts and Jobs Act (TCJA) is set to end at the close of this year, resulting in a federal estate exclusion that is less than half of the current $13.99 million exclusion. Other changes to the tax structure are...more

Proskauer Rose LLP

Wealth Management Update - February 2025

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February 2025 Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intra-Family Loans and Split Interest Charitable Trusts - The February applicable federal rate (“AFR”) for use with a sale to a defective grantor...more

Offit Kurman

The Estate Planning Benefits of Marriage: What Unmarried Couples Need to Know

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It is becoming increasingly commonplace for people to enter long-term romantic relationships without legally marrying. While there are no exact statistics on how many Americans fall into this growing category, a 2019 Pew...more

Cohen Seglias Pallas Greenhall & Furman PC

Breaking Down the IRS's 2025 Inflation Adjustments for Estate and Gift Planning

The IRS has released new inflation-adjusted figures that can impact your estate and gift planning. These numbers seem like a lot to sift through, but understanding them could make a big difference in your financial future....more

Adler Pollock & Sheehan P.C.

How an HSA Can Benefit Your Estate Plan

A Health Savings Account (HSA) can positively affect your estate plan. How? In addition to serving as a viable option to reduce health care costs, an HSA’s funds grow on a tax-deferred basis. In fact, an HSA is similar to a...more

Offit Kurman

Equal Shares, Unequal Outcomes: Estate Planning Strategies for Parents and their Qualified Retirement Accounts

Offit Kurman on

Typically, a parent wishes to treat their children equally in their estate plan and presumes they will achieve this goal by dividing all their assets into equal shares upon their death. Accordingly, they will designate their...more

Kohrman Jackson & Krantz LLP

Act Now or Pay Later? Estate Planning Strategies Before the 2025 Tax Sunset

The current federal estate tax exemption levels, introduced by the Tax Cuts and Jobs Act (TCJA) in 2018, have provided historically high federal estate tax exemptions. But this period of increased exemption is expected to...more

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